ML20236E963
| ML20236E963 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/21/1987 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 WM-87-0197, WM-87-197, NUDOCS 8708030156 | |
| Download: ML20236E963 (5) | |
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WQLF CREEK NUCLEAR OPERATING CORPORATION Bart D. Withers President and.
Chief Executive officer July 21, 1987
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I 3E R. D. Martin, Regional Administrator U.S. Nuclear Regulatory Conmission f/
Region IV 611 Ryan Plaza Drive, Suite 1000 t
Arlington, Texas 76011 Letter: WM 87-0197 Re:
Docket No. 50-482 l.
Subj:
Meetir,g on WCGS Emergency Classification Schene Dear Mr. MartitM On July' 9, 1987 I received a letter from Mr.
Eric Johnson of your staff requesting a neeting to discuss what are perceived to be deficiencies in the Wolf Creek Generating Station (hCGS). emergency classification scheme (Reference 1).
Frcn the information provided in the letter it is difficult to determirra
.whether the NRC believes we need to revise the WCGS Radiological Emergency Response Plan (RERP) to more fully conply with the regulations and WCGS commitments or to be more consistent with the guidance of NUREG-0654.
If we do not meet WCGS commitments to the NRC or the regulations we will be very responsive to the establishment of a schedule to bring WCGS back into compliance.
However, we are concerned if the objective is to have WCGS revise its RERP nerely to be more consistent with NUREG-06r>4.
While NUREG-0654 is the primary guidance document used by the NRC to. review REPPs, it is a guidance document and not a requirement.
Other alternative approaches to-cmergency planning are allowed provided they are found acceptable to the NRC.
The WCGS alternative approach to the emergency classification system g
was developed by WCGS to be an innovative and improved emergency classification ; method and was extensively reviewed by the NRC prior to the Staff's approval in December, 1983.
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PDR jyh P.O. Box 411/ Burlington, KS 66839 / Phone; (316) 364 8831 g
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WM 87-0197 Page 2 July 21, 1987 The' key feature of the WCGS RERP's symptomatic approach is the. number of fission product barriers which have been challenged or degraded.
The classification schene is independent of the initiating event and does not require the identification of the failure sequence or the cause to properly classify the hazard level in relationship to public health and safety.
Since-barrier degradation indication is not dependent upon any specific indication but tends to exhibit numerous conditions throughout the plant, operators are able to properly classify the emergency level throughout an event with high probability of accurate classification.
When an event-related classification scheme is enployed, such as that of NUREG-0654, proper classification is dependent upon proper identification of the event.
If the identification of the event is not correct, the probability of inappropriate protective actions is increased. The emergency classification criteria described in the NCGS RERP provides direction to the operators relative to any event, regardless of cause, and provides a criterion upon which to base judgenents as to whether mitigating efforts have been successful in retaining those fission product barriers not compromised by
.the event.
The WCGS emergency classification system and its underlying philosophy is extensively documented in several submittals to the Staff (References 2, 3,
& 4 provide examples) and in the Staff's review and approval of our subnittals (References 5, 6,
& 7).
For exanple in Mr.
Johnson's letter (Reference 1) in the first paragraph on page 2, the statement is made that "In addition, the NCGS EAL scheme does not include several exanple events of NUREG-0654, such as the loss of function needed for shutdown, security events, loss of power, natural events, and evacuation of the control room.
These are classified initially as unusual events, but are not escalated unless a fission product barrier is breached or a breach is intninent".
A discussion on the classification of emergencies not related to plant malfunctions was submitted to the Staff in 1983 (Reference 3, O I.c).
Based on this and other information the Staff concluded that
...the NCGS energency classification system can adequately assess and classify emergencies other than those arising directly from plant malfunction."
(Reference 5, Section 13.3.2.4).
At WCGS we believe energency planning is extremely inportant and we have put i
a tremendous amount of effort in the development of our emergency response plan.
Comparisons between our program and the guidance of NUREG-0654 have been the subject of extensive correspondence and several meetings between NCGS and the NRC Staff.
Substantial licensing documentation er.ists to document the review and approval of our program.
We firmly believe our i
current emergency response plan is effective in terms of protecting the I
health and safety of the public.
We recognize that the Staff can and will periodically change its technical interpretation concerning what is acceptable. However, if the Staff changes its interpretation after its initial acceptance, the plant specific backfit provisions of 10 CFR 50.109 and NRC Manual Chapter 0514 are applicable anS should be conplied with prior to inposing the changes on the utility.
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a e n WM 87-0197 Page 3 July 21, 1987 Therefore, if the purpose of the neeting is to have WCGS's currently approved RERP changed to fall more in line with the guidance of NUREG-0654, we could discuss the inpacts and implications of those inposed changes to assist you in your backfit assessment, but it would not be appropriate to discuss an implementation schedule until the Staff has conpleted the actions required by 10 CFR 50.109.
'Ihere are two specific points in the Reference 1 letter that need further discussion.
The first point is that the NRC professes that the delay in upgrading to a General Rnergency during our last energency response exercise supports the stated conclusion that the WCGS RERP is less conservative than NUREG-0654.
We have reviewed the NCG3 plan against the prescriptive guidance of NUREG-0654 in this area and have concluded that the delay in the DEM's upgrading of the emergency classification would have occurred regardless of which guidance was in place.
Both NUREG-0654 aM the NCGS
. approved RERP bases the decision to upgrade the classification on the DEM's judgnent and anticipation of containment failure.
We responded previously to your concern in this area and have. agreed that the DEM should have been more conservative.
Therefore, we do not believe the example justifies the escalation of the previous concern from an " Improvement Item" to a program deficiency.
Second, the statement that the
"...NCGS plan might be inadequate..."
concerns us.
It is difficult for us to see any support in the record for this statenent from anything provided by the NRC to date.
In fact, the be.lk of the evidence in terms of several very successful exercises and the detailed review ard approval of the plan would support a positive conclusion.
As was discussed in the previous paragraph, the example cited was an isolated problem with the lack of conservatism displayed by the DEM and not a problem with the plan.
Duergency plans cannot be proceduralized to the point that removes all judgment. Sone degree of judgment will always be required and there is no plan that can be written to guarantee that the judgnents of'the DEM will always be consistent with or as conservative as that of the evaluators.
It is our intent that the DEM makes decisions based upon the best available information and his knowledge of the plant while attenpting to anticipate future events.
We learn from our mistakes in exercises.
We must realize that " mistakes" made during exercises form a large part of the educational process of the players exercising and being critiqued afterwards,- and that revising the plan is not necessary in many cases.
In sungnary, WCGS will have appropriate peruonnel at the July 29, 1987 meeting to discuss our RERP.
If the Staff has identified areas in our RERP that fail to meet the requirements, we will be able to establish a schedule for making the necessary changes.
If, however, the Staff is asking WCGS to change the approved energency response plan to be more consistent with
-NUREG-0654, we will assist you in assessing the impact for backfit analysis
l WM 87-0197 Page 4 l
July 21, 1987 1
i purposes but NCGS does not believe it is appropriate to establish a schedule for changes until these proposed changes are subjected to the requirements j
of 10 CFR 50.109.
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l If you have any questions concerning this matter, please contact me or Mr.
O. L. Maynard of my staff.
Very truly youra,
=_J Bart D Withers President and Chief Executive Officer BIM/jad cc:
PO'Connor (2)
JCunmins CHackney EJohnson i
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'Y REFERENCES i
1.
Letter dated 7/7/87 from EHJohnson, NFC, to BDWithers, WCNOC 2.
Letter IHLNRC 83-011 dated 1/21/83 from GLKoester, KG&E, to HRDenton, NRC 3.
Letter KMLNRC 83-129 dated 10/10/83 fran GLKoester, E&E, to HRDenton,.NRC
~4.
Letter INLNRC 83-148 dated 11/21/83 from GLKoester,.lX3&E, to HRDenton, NRC 5.
NUREG-0881, Supplement No. 4, " Safety Evaluation Report Related to j
the Operation'of Wolf Creek Generating Station Unit No.
1", December, 1983 6.
NUREG-0881, Supplement No. 5, " Safety Evaluation Report Related to the Operation or Wolf Creek Generating Station Unit No.1", March,1985 7.
NUREG-0881, Supplement No. G, " Safety Evaluation Report Related to the Operation of Wolf Creek Generating Station Unit No.1", June,1985
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